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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

January 9, 2017

The Year in Review

As we move into 2017, the Take on Payments team would like to share its perspectives of major payment-related events and issues that took place in the United States in 2016, in no particular order of importance.

Cybersecurity Moves to Forefront—While cyber protection is certainly not new, the increased frequency and sophistication of cyber threats in 2016 accelerated the need for financial services enterprises, businesses, and governmental agencies to step up their external and internal defenses with more staff and better protection and detection tools. The federal government released a Cybersecurity National Action Plan and established the Federal Chief Information Security Office position to oversee governmental agencies' management of cybersecurity and protection of critical infrastructure.

Same-Day ACH—Last September, NACHA's three-phase rules change took effect, mandating initially a credit-only same-day ACH service. It is uncertain this early whether NACHA will meet its expectations of same-day ACH garnering 1 percent of total ACH payment volume by October 2017. Anecdotally, we are hearing that some payments processors have been slow in supporting the service. Further clarity on the significance of same-day service will become evident with the addition of debit items in phase two, which takes effect this September.

Faster Payments—Maybe we're the only ones who see it this way, but in this country, "faster payments" looks like the Wild West—at least if you remember to say, "Howdy, pardner!" Word counts won't let us name or fully describe all of the various wagon trains racing for a faster payments land grab, but it seemed to start in October 2015 when The Clearing House announced it was teaming with FIS to deliver a real-time payment system for the United States. By March 2016, Jack Henry and Associates Inc. had joined the effort. Meanwhile, Early Warning completed its acquisition of clearXchange and announced a real-time offering in February. By August, this solution had been added to Fiserv's offerings. With Mastercard and Visa hovering around their own solutions and also attaching to any number of others, it seems like everybody is trying to make sure they don't get left behind.

Prepaid Card Account Rules—When it comes to compliance, "prepaid card" is now a misnomer based on the release of the Consumer Financial Protection Bureau's 2016 final ruling. The rule is access-device-agnostic, so the same requirements are applied to stored funds on a card, fob, or mobile phone app, to name a few. Prepaid accounts that are transactional and ready to use at a variety of merchants or ATMS, or for person-to-person, are now covered by Reg. E-Lite, and possibly Reg. Z, when overdraft or credit features apply. In industry speak, the rule applies to payroll cards, government benefit cards, PayPal-like accounts, and general-purpose reloadable cards—but not to gift cards, health or flexible savings accounts, corporate reimbursement cards, or disaster-relief-type accounts, for example.

Mobile Payments Move at Evolutionary, Not Revolutionary, Pace—While the Apple, Google, and Samsung Pay wallets continued to move forward with increasing financial institution and merchant participation, consumer usage remained anemic. With the retailer consortium wallet venture MCX going into hibernation, a number of major retailers announced or introduced closed-loop mobile wallet programs hoping to emulate the success of retailers such as Starbucks and Dunkin' Brands. The magic formula of payments, loyalty, and couponing interwoven into a single application remains elusive.

EMV Migration—The migration to chip cards and terminals in the United States continued with chip cards now representing approximately 70 percent of credit/debit cards in the United States. Merchant adoption of chip-enabled terminals stands just below 40 percent of the market. The ATM liability shift for Mastercard payment cards took effect October 21, with only an estimated 30 percent of non-FI-owned ATMs being EMV operational. Recognizing some of the unique challenges to the gasoline retailers, the brands pushed back the liability shift timetable for automated fuel dispensers three years, to October 2020. Chip card migration has clearly reduced counterfeit card fraud, but card-not-present (CNP) fraud has ballooned. Data for 2015 from the 2016 Federal Reserve Payments Study show card fraud by channel in the United States at 54 percent for in person and 46 percent for remote (or CNP). This is in contrast to comparable fraud data in other countries further along in EMV implementation, where remote fraud accounts for the majority of card fraud.

Distributed Ledger—Although venture capital funding in blockchain and distributed ledger startups significantly decreased in 2016 from 2015, interest remains high. Rather than investing in startups, financial institutions and established technology companies, such as IBM, shifted their funding focus to developing internal solutions and their technology focus from consumer-facing use cases such as Bitcoin to back-end clearing and settlement solutions and the execution of smart contracts.

Same Song, Same Verse—Some things just don't seem to change from year to year. Notifications of data breaches of financial institutions, businesses, and governmental agencies appear to have been as numerous as in previous years. The Fed's Consumer Payment Choices study continued to show that cash remains the most frequent payment method, especially for transactions under 10 dollars.

All of us at the Retail Payments Risk Forum wish all our Take On Payments readers a prosperous 2017.

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May 31, 2016

What Is GPR Feeding On? Part 1 of 2

I recently gave a presentation titled "Where We Are Going, We Won't Need Checking Accounts" at the NACHA Payments Conference in Phoenix. This session focused on the increasing use of alternative financial accounts such as general purpose reloadable (GPR) cards in place of traditional bank accounts. After the presentation, I overheard an attendee comment, "I don't even understand why a product like prepaid exists, when the majority of its use is attributed to those seeking anonymity to conduct fraud." While I will cover common prepaid fraud schemes in the next installment, first I think it is important to consider why prepaid products like the GPR card deserves a seat at the payments table.

I'll start with an egalitarian comparison. Consumers have the right to choose a leather or Velcro wallet and then store their cash in that wallet. In today's digital world, shouldn't a consumer also have the right to acquire a GPR card, e-wallet, or other account to store money electronically? If a consumer receives or spends money illegally in any form, then the justice system should enforce the law. Funds stored in a GPR account or a demand deposit account (DDA) is e-money, a representation of cash in your wallet. The GPR card is an access device to the stored money, functioning like the beloved debit card to the DDA.

In June 2015, the Pew Charitable Trusts published Banking On Prepaid, a report of the motivations and views of prepaid card users. The study concludes that the main reasons for prepaid card use for both banked and unbanked users are to avoid overdraft fees, debt, and check cashing fees. In addition, most GPR users are attracted to the budgeting and savings tools provided by these types of accounts. The report also found that most GPR users don't aim to be anonymous: 74 percent of unbanked GPR cardholders registered their cards, and 52 percent of banked cardholders registered. The primary benefit to registering is that the cardholder gets consumer protections like limited liability and, in many cases, insurance from the Federal Deposit Insurance Corporation.

Susan Herbst-Murphy and Greg Weed, in their 2015 paper "Millennials with Money Revisited," collected data that challenges preconceptions of GPR cards as a product for low-income and unbanked customers. These researchers identify a "power user" group of young, banked, middle- to upper-income levels as well as a "hybrid" user group that combines GPR accounts with traditional bank accounts and other alternative financial services. They suggest we look to the power users to understand why and how the product is being used.

Clearly, there is a market with a strong appetite for this financial product.

Stay tuned for the next installment, when we examine the GPR market for bad apples.

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January 11, 2016

Prisoner Release Cards: How to Protect the Interests of Recently Released Inmates?

I recently watched a late-night comedian criticize prison reentry programs in the United States. The segment focused on the resources—or lack thereof—that are provided to released inmates. One of these resources, I have recently learned, is increasingly a prepaid card.

Upon imprisonment, inmates are given a trust account to hold money that they receive for prison work and from family and friends. When they are released, they may also receive start-up funds to help with the reentry process. According to the Federal Bureau of Prison's Inmate and Custody Management Policy, "an inmate being released to the community will have suitable clothing, transportation to inmate's release destination, and some funds to use until he or she begins to receive income. Based on the inmate's need and financial resources, a discretionary gratuity up to the amount permitted by statute may be granted." While the policy expands the details of what constitutes suitable clothing and the method of transportation, there is no mention of how to disburse funds to the released individuals.

Enter prison-release prepaid cards. Many state and federal prison systems enter into contracts with prepaid card providers pursuant to a public bidding process to provide prison release funds through a prepaid card as an alternative to cash or checks. This shift in disbursement methods may be attributable to concerns about cash controls in the prison setting and the high check-cashing fees some inmates who lack traditional bank accounts incur, to name a couple of possibilities. Regardless of the disbursement method that the correctional agency chooses, this vulnerable population depends on every last penny.

Some people maintain that account fees are too high on these prepaid cards and that agreements with cardholders contain forced arbitration clauses. Could the correctional agency negotiate better terms on behalf of the released prisoner? Or could the inmate possibly be given options for the trust fund distribution—cash, check, prepaid card, or even a Paypal account?

A late-night comedian may have the ability to isolate one slice of the problem with prison release programs, but our regulations shouldn't piece together a solution to an overarching issue. Likewise, there are challenges with creating blanket regulations for a product category like prepaid cards that contains many different products meeting a wide variety of distinct needs, each with unique characteristics and different users. Isn't the goal is to provide released prisoners the freedom to use money that belongs to them, as for any other citizen?

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November 16, 2015

Is It Bigger Than a Bread Box?

The answer is yes and no. A payment card in physical form clearly is not bigger than a bread box, but it certainly is a symbol of something bigger. The card is an access device to an account. It could be a birthday gift to my favorite Italian restaurant, a debit card issued by my bank, a general purpose reloadable prepaid card purchased at my local pharmacy, or a card accessing a credit line, and the list goes on. You can't just say, “I used a plastic card to pay for my Italian dinner” and have someone know exactly which card type was used.

Let's play the classic 20-questions game, Take On Payments-style. I'll be thinking of a type of financial account, and you guess the type of account based on the 20 features below. Good luck!

Connects you to more than one account and allows you to manage multiple accounts under one main account.

Issues mobile alerts.

Has optional plastic card; can be all-virtual management.

Offers mobile check deposit.

Allows stop payments on previously scheduled transactions.

Offers the ability to cover some purchase transactions over the account balance.

Accepts direct deposit via ACH for payroll or other deposits.

Allows you to order checks on the account and pay bills with a check.

Which account type did you guess? If I were to tell you that what I had thought of was a prepaid account, would you be surprised? I was thinking of prepaid as bigger than a bread box. It's not a card, or payment channel; it is an account type. Payment transactions are sent to and from a prepaid account just like a checking account. The financial institution and program manager determine the account name and features, and where accounts can be opened.

However, the payments industry needs to be careful that marketing differences don't lead to the misperception that these accounts are fundamentally different from checking accounts. If we let perceptions cloud the true purpose these accounts serve—it is essentially a transaction account, just sold differently—then regulations and risk controls may not address the actual risks. It is inconsistent to regulate transaction accounts offering the same services based on how the account was opened and the type of organization servicing the account, unless the regulation is addressing the actual risk injected at those points. In order for consumer protections and compliance to be achieved consistently, risk controls and regulations should address the operational aspects of these transaction accounts, rather than the marketing name assigned to it.

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August 24, 2015

Payroll Cards at Interstate Speed

State lines happen fast in New England, which is where I call home. In this part of the country, it's not uncommon for people living in one state to commute for employment to a neighboring state. One could pay property tax enjoying the motto "Live free or die" (New Hampshire) while paying income tax to the Bay State (Massachusetts). Employees may not take much notice of state employment law, but employers almost certainly do. I'm thinking that minimum wage, tax rates, and corporation law would be key factors for an employer to consider, but do payroll card laws also fit into the evaluation?

Payroll cards are prepaid cards onto which an employer loads wages. They offer an alternative to paychecks or direct deposits, and are subject to a different sort of regulation. Outside of a federal law prohibiting an employer from mandating the exclusive use of a payroll card, states are generally free to develop their own legislation governing payroll cards. In Maine, for example, employers can offer payroll cards if they give their employees free access to full pay. Connecticut goes one step further, requiring employers to provide certain disclosures and prohibiting overdrafts and certain fees. Massachusetts does not have any law for or against payroll cards. Somewhere in the middle is Vermont, which allows payroll cards with certain disclosures as long as employees receive three free transactions monthly. Proposed New York legislation would go so far as to require employees to sign a written consent form—printed with a large, 12-point font—to be retained for six years following the cessation of the employment relationship.

And that's only in my home of New England. Out of 50 possibilities, I've mentioned only fragments of only five state laws. Outside of this area, payroll-card-related legislation is being introduced or pending in 12 states.

Regulation E has covered payroll cards since 2006. Regulation E includes (i) protection to employees so they do not have to receive wages via electronic funds transfers with a particular institution; (ii) access to statements, balances, and transaction histories; (iii) clear and conspicuous disclosures; and (iv) error resolution and limited liability. In January 2016, we expect the final version of the Consumer Financial Protection Bureau's Rule on Prepaid to be published.

Because payroll cards are already covered under Regulation E, only two significant issues are applicable in the pending rule. First, credit and overdraft services, while not prohibited, will be subject to compulsory use provisions and Regulation Z's definitions of credit and periodic statement requirements. Second, disclosures will carry a bold print warning, "You do not have to accept this payroll card. Ask your employer about other ways to get your wages."

What federal regulation doesn't touch is the type and amount of fees assessed on payroll cards. Regulation E provides only that fees are disclosed. Certain industry stakeholders such as National Branded Prepaid Card Association, Consumer Action, MasterCard, and the Center for Financial Services Innovation have worked to develop industry standards. Simply speaking, most agree that cardholders should have access to full wages each pay period without cost and that they should be able to perform basic functions without incurring unreasonable fees.

Best practices give the industry the ability to fill gaps and stay nimble to changing technology, fraud schemes, and consumer needs. The CFPB even says in their proposed rules, "Employees may not always be aware of the ways in which they may receive their wages, because States may have differing and evolving requirements." Does state-by-state regulation ultimately fill the gaps needed, especially in a system that crosses state lines so often?

Comments

Studies by the Federal Reserve and others show the least expensive and most convenient method for a LMI employee to receive their pay is a payroll card. As noted in this article it is also the most regulated. Why so much attention is given to payroll cards when 80% of employees are direct deposit and faced with exorbitant bank fees for overdrafts and minimum balance is mind boggling. The premise that if it is offered by the employer it must be bad for the worker is painting an entire population with the same prejudicial brush

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December 22, 2014

Top 10 Payments Events in 2014

As the year draws to a close, the Portals and Rails team would like to share its own "Top 10" list of major payments-related events and issues that took place in the United States this year.

#10: Proposed prepaid rule. After a long wait, the Consumer Financial Protection Bureau issued its proposed rules on general reloadable prepaid cards in November. While the major players in the prepaid card industry had already adopted most of the practices included in the proposed rule, the proposal allowing overdrafts and credit extensions is likely to generate differing perspectives during the comment period before a final rule is adopted in 2015.

#9:Regulation II. The U.S. Circuit Court of Appeals for the District of Columbia upheld the Federal Reserve Bank's rules regarding interchange fees and network routing rules, reversing a 2013 decision. Notice of appeal on the interchange fee portion of the ruling has been given, but resolution of the network routing rules has cleared the way for the development of applications supporting routing on chip cards.

#8: Payment trends. The detailed Federal Reserve Bank's triennial payments study results were released in July 2014, continuing the Fed's 15-year history of conducting this comprehensive payments research. Cash usage continued to decline but remained the most-used form of payment in terms of transaction volume.

#7: Card-not-present (CNP) fraud. With the growing issuance of chip cards and the experience of other countries post-EMV migration—with substantial amounts of fraud moving to the online commerce environment—the payments industry continues to search for improved security solutions for CNP fraud that minimize customer friction and abandonment.

#6:Faster payments. Continuing a process it began in the fall of 2013 at the release of a consultative white paper, the Federal Reserve Bank held town halls and stakeholder meetings throughout the year in preparation of the release of its proposed roadmap towards improving the payment system.

#5: Virtual currencies. Every conference we attended had sessions or tracks focused on virtual currencies like Bitcoin. While there was some advancement in the acceptance of Bitcoin by major retailers, the number of consumers using the currency did not rise significantly.

#4: Mobile payments. The entry of Apple with its powerful brand identity into the mobile payments arena
with Apple Pay has energized the mobile payments industry and brought improved payment security through tokenization and biometrics closer to the mainstream. (Apple Pay's impact on mobile payment transaction volume will likely be negligible for a couple of years.) Additionally, the use of host card emulation, or HCE, as an alternative contactless communications technology provides another option for mobile wallet development.

#3: EMV migration. The frequency and magnitude of the data breaches this year have spurred financial institutions and merchants alike into speeding up their support of EMV chip cards in advance of the October 2015 liability shift.

#2: Third-party processors. Regulators and law enforcement escalated the attention they were giving to the relationships of financial institutions with third-party processors because of increased concerns about deceitful business practices as well as money laundering.

And…drum roll, please!

#1: Data breaches. The waves of data
breaches that started in late 2013 continued to grow throughout 2014 as more and more retailers revealed that their transaction and customer data had been compromised. The size and frequency of the data breaches provided renewed impetus to improve the security of our payments system through chip card migration and the implementation of tokenization.

How does this list compare to your Top 10?

All of us at the Retail Payments Risk Forum wish our Portals and Rails readers Happy Holidays and a prosperous and fraud-free 2015!

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November 17, 2014

Consumer Prepaid Protections May Be Catching Up with Prepaid Use

On November 13, the Consumer Financial Protection Bureau (CFPB) issued its much-anticipated notice of proposed rulemaking of consumer protections for the prepaid market. This proposed rule covers multiple facets related to the prepaid industry, including disclosure requirements, fraud protection, access to account information, and the provisioning of credit via overdraft. Today's blog will provide a brief, high-level summary of this rule.

What is and isn't covered under this rule?
This rule redefines a "prepaid account" under Regulation E (Reg E). Prepaid products include cards, codes, and other devices capable of being loaded with funds that are not currently covered by Reg E and are usable at multiple, unaffiliated merchants and ATMs, and for person-to-person transfers. Gift cards, and certain related cards, are excluded.

Disclosure requirements
The rule requires that card issuers use two forms to disclose fees. The short form discloses four types of fees: monthly account fees, cash reload fees, ATM transaction fees, and purchase transaction fees. The rule proposes the use of a model form that establishes a safe harbor for compliance to the short-form requirement. The long form describes all of the potential account fees and the conditions under which these fees are assessed, as well as the fees that short form includes. Both disclosures must be made available to the consumer before the opening of an account.

Fraud protection
The rule modifies Reg E to require that issuers adopt error resolution procedures and limited liability for prepaid accounts. Reg E coverage limits a prepaid consumer's liability for unauthorized transfers to $50, assuming that the consumer gives timely notice to the financial institution and the card has been registered. Further, financial institutions would be required to resolve certain errors to prepaid consumer accounts.

Access to account information
The rule also modifies Reg E to require that financial institutions provide prepaid account holders with free access to periodic statements or that they make available to the consumer the account balance and at least 18 months of account transaction history. These periodic statements and transaction histories must include a summary of monthly and annual fees in addition to a listing of all deposits and debits.

Overdraft protection
The rule allows for issuers of prepaid accounts to offer overdraft services and other credit features. However, issuers that offer these services or features for a fee are subject to Regulation Z (Reg Z) credit card rules and disclosure requirements which, among other things, requires them to evaluate whether consumers can repay their debt. The issuer is required to obtain a consumer's consent before adding these services to accounts and must provide consumers with a periodic statement of the credit and provide at least 21 days to repay the debt. Should a product offer overdraft or other credit features, it must be disclosed in the disclosures of the short and long forms.

The CFPB is seeking public comment for a 90-day period, beginning with its publication in the Federal Register.

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January 28, 2013

Do GPR Prepaid Cards Pose Significant Money Laundering Threats?

When it comes to laundering proceeds from illicit activities, criminals have historically had a number of financial instruments and methodologies at their disposal. These choices have ranged from payment products tied to demand deposit accounts such as checks, wires, and debit/ATM card transactions to money transfers via money transmitters. The birth of general purpose reloadable (GPR) prepaid cards in the early 1990s created yet another payment instrument that could potentially be used to clean dirty money.

Although no payment instrument—GPR prepaid cards included—is completely immune to money laundering, the payments industry can adopt risk measures to mitigate the attractiveness of these cards to criminals. But what makes a payment choice attractive to money launderers? Criminals generally seek the fastest method to move their ill-gotten proceeds the furthest away from their illegal activities. Ultimately, they want to distance themselves and their financial gain from the crime in the quickest way possible. Anonymity, accessibility, immediate liquidity, and transportability of funds are all payment characteristics that a money launderer finds attractive.

The Retail Payments Risk Forum dove into the regulatory environment and risk management practice of the GPR prepaid card industry, and wrote up findings in a paper available on the Atlanta Fed's website. Among the paper's findings is that, as GPR prepaid cards have grown in popularity and come under increased scrutiny by regulators, significant regulatory measures and industry-wide adopted practices have greatly reduced, but not eliminated, their money laundering risks. And while U.S. regulators and the card industry have made great strides with anti-money laundering measures, GPR prepaid cards issued internationally do not necessarily face the same stringent risk environment, so they pose significant money laundering risks.

For more details on the money laundering risk environment for GPR prepaid cards, read the paper.

Comments

Interesting paper. The DoJ paper and rebuttal go into greater depth on the actual risks of GPR's in money laundering.

GPR's are not really like any other financial tool. Most are tied to a bank DDA with explicit account opening procedures.

What would be interesting is an analysis of recent GPR innovations which allow individuals "deposit-only" capability. Basically these are simple pieces of plastic that allow ground level drug dealers to deposit cash sales into a master account any where in the country.

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November 13, 2012

The Rule of 3, or Desperately Seeking Payment Products

Generally speaking, I have always believed in the "Rule of 3." When you're looking for something new—with your home, for example, or with your clothing style—try out three, and the obvious will likely emerge as a winner. When I had my design business and helped people pick products out for their homes, I never presented them with more than three options for any one product. If I did, sure enough they would get frustrated and become unlikely to make a confident decision.

When I changed career paths here at the Fed and entered the world of retail payments, I decided to look into some new payment products and services for my children. I am the mother of teenagers who are always asking for money, so my first goal was to provide them with a safe, easy, and secure way to have and spend money.

I began to research some products, and narrowed my choices down to three options to explore: gift cards, prepaid debit cards, and bank-issued debit cards. Immediately, I eliminated gift cards, which once depleted are usually not reloadable. I wanted this to be a lifestyle change, something that could be extended; therefore, I focused my research on option number 2, reloadable cards. I started at a local grocery store, where I stood looking in awe at the tower of choices I had before me. Most cards here cost $4.95 before you load money on them. A store clerk told me that a big-box retailer had the same products for $3, so off I went.

The first purchase was for my son. At the checkout, I asked the clerk to load $40 on the card. The clerk informed me that I could not use my credit card to fund a prepaid card—I needed cash, or a preprinted payroll or government check, or direct deposit from my paycheck, or a standard transfer from my bank that could take up to 13 days—and then I would be charged a fee.

This did not seem very user-friendly, especially since I do not carry an ATM card, nor do I frequent this big-box retailer often. But I was determined to try this new payment method, so I returned the next day and paid $3 to buy a $40 card. (I now know that this $3 fee is waived if you get your card online and that there is a reload fee of $3 and a monthly maintenance fee of $3.) This still seemed like a better option than a bank debit card. I registered the card online for my son (required for activation) and entered personal information like name, address, and social security number. I was not thrilled with that level of privacy loss—however, as the small print explained, "Federal law requires us to obtain, verify, and record information that identifies you when you open up this account." In addition, this is the only way I could get a refund if the card were lost or stolen, and that was one of my three preliminary requirements.

So I started looking for the actual custom card in the mail with my son's name on it. I waited two weeks—and no card. I reviewed the fine print included inside the package to discover that you must be over the age of 16 to buy and use this kind of card. This information was printed nowhere on the outside of the packaging. My son is 15, not even 16 yet. So, there will not be a custom card coming in the mail, and this temporary card I have will become useless once the balance falls to zero. Have I mentioned that there is a $3 monthly maintenance fee that applies after the tenth day you have the card? So far, I have paid $6 to lend him $40 on a card that is not reloadable.

This led me to option number 3, my bank, where I learned about student accounts that don't charge for bank-issued debit cards. And, for convenience, I can transfer funds from my checking account into the student account, which funds the debit card. Honestly, this was not my first choice, but it emerged as the safest, cheapest, and most convenient. I decided to use this opportunity to teach my kids about online banking, overdraft fees (because I am not linking the student account to my account), the importance of passwords, and balancing their (virtual) checkbooks.

This account has proven to be a wonderful tool, and my kids now look forward to logging in and checking their balances and confirming that their "payday" has been deposited upon completion of their agreed-upon chores. I can't wait to discover more opportunities of my new job here in the Forum!

Comments

I am surprised that you did not come across the prepaid "teen" card offerings such as Visa Buxx, which is a prepaid card specifically designed for parents with teenagers who would like to provide their child with a bank account type of relationship. The beauty of the teen card is that there are 2 account holders and one card holder. The parent has total visibility on the account and can load funds (without a fee from a checking account) from any source, even limit where the card is used and look at the account activity. The teen, can use the card anytime any place and also monitor statements on line. This product has become very popular with high school and college students and it has all the safety and security of a DDA account without having to keep a minimum balance or having the risk of over drafting the account. It is definitely worth looking into.

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October 29, 2012

Crossing the Border: More Reason to Check Your Pockets

It's no secret that cross-border travel has involved a lot more restrictions since 9-11. Declaration of assets and physical inspection of luggage and other items are expected, as well as tedious and unpleasant, aspects of a vacation or business trip. That could change soon and not for the better, under a new rule proposed October 2011 by the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The new rule would require travelers to add the balances of prepaid cards to declaration reports.

While issuing such a rule sounds reasonable in theory, enforcement is likely to be another matter. Unlike checking the content of physical items, digital value stored in or accessed by a plastic card or a mobile phone is difficult to measure. How can you tell how much money is loaded on the prepaid card to validate the declared value? In fact, how will enforcement officials even distinguish prepaid cards from credit and debit?

FinCEN's proposed rulemaking expected to be final soon
FinCEN's Notice of Proposed Rule Making (NPRM), expanding the scope of its cross-border reporting requirements to include "tangible prepaid access devices," is poised to assume its final form, some expect as soon as the end of the year. Currently, travelers have to report aggregated cash and other monetary instruments exceeding $10,000. The premise behind this requirement is that it prevents money laundering and criminal-terrorist financing by enabling the traceability of currency and its equivalents, and hopefully eliminating anonymous flows of money into and out of the United States.

Previously, FinCEN issued a rule recognizing the advanced innovations in prepaid payment methods and the subsequent need to expand the definition to include all form factors backed by prepaid value, in addition to cards. That rule also changed the payment method definition from "stored value"—implying value stored digitally within the form factor—to "prepaid access," a term that more accurately describes the process for electronic retrieval of prepaid funds maintained by the payment provider.

Handheld readers at borders and airports?
According to comments published in response to the NPRM, the Department of Homeland Security is working on a "handheld reader with features that will, among other things, allow law enforcement to quickly and accurately differentiate between a traveler's debit, credit, and prepaid products…in a manner which imposes minimal to no inconvenience to individuals and complies with U.S. laws, regulations, and procedures." Furthermore, according to the comments, the enforcement challenge is not new, nor is the concept of a device or document that can be used to access value. The current challenges are similar to those presented in the past with other monetary instruments such as checks, money orders, and traveler checks.

Still keeping an eye on bulk cash
A recent study conducted by U.S. and Mexican officials reported that stored-value and prepaid cards are "potentially powerful means for both transporting and laundering money," but still found that the majority of illicit funds movement across the U.S. and Mexican border takes place in the form of bulk cash. In fact, most of the criminal movement of funds does not involve laundering, which is typically accomplished by first depositing illicit funds into a bank or business before moving it. This is particularly important in addressing criminal terrorist financing that may only involve transport. It will be important for regulators to strike a balance between proactive enforcement in addressing crime in electronic channels and effective management of more basic schemes involving the transport of cash across borders.

Many questions still remain
Many commenters to the NPRM have expressed opposition to the premise that prepaid access devices should be classified as monetary instruments since they merely access funds held at a bank or financial institution. When law enforcement takes possession of a cash or monetary instrument at the border, they are effectively holding the funds, but not so with a prepaid card or other device. Holding the card does not provide access to the underlying funds. Furthermore, the legislation is easy to evade. According to a comment from the Network Branded Prepaid Card Association, "a card can truthfully be reported as having just $1,000 on it; and then two hours later, the card can be loaded with funds from another location and have $15,000 on it."

Commenters also suggested alternatives that would focus the final-rule decision making on more effective measures, such as carrying a large number of cards, particularly if the cards are not embossed with the cardholder's name. For example, a person carrying more than 20 nonpersonalized cards would have to declare the aggregated value and be prepared to address questions by border patrol agents. Such a measure could avoid the need for high-cost readers and the potential privacy issues that may ensue if the final rule is issued as proposed.

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